DRC-2011-007037 - 0901a0688024edc2

State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DFVISION OF RADIATION CONTROL
Rusty Lundberg
Director
July 7, 2011
CERTIFIED MAIL
(Return Receipt Requested)
David C. Frydenlund, Vice President, Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 n'^ Street, Suite 950
Denver, CO 80265
Subject: Nitrate Investigafion Phase 2 Detailed Work Plan and Schedule dated June 30, 2011:
DRC Review Comments
Dear Mr. Frydenlund:
DRC review comments regarding the June 30, 2011 Denison Mines (USA) Corporafion "Nitrate
Investigation Phase 2 Detailed Work Plan and Schedule" are enclosed (via URS Memorandum). Please
ensure that all conmients are addressed and resolved in the revised work plan.
If you have questions or concems regarding the comments, or would like to arrange a meeting or
teleconference to discuss the comments, please contact me at [phone]. Thank you.
Thomas Rushing, P.G.
Geotechnical Services Section
Enclosure: URS Memorandum (4 pp)
F:\DUSA\Nitrate Contamination InvestigationVPhase 2 Detailed Work Plan\Phase 2 Detailed Work Plan DRC Comments Cover Ltr.doc
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq. utah.gov
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URS
MEMORANDUM
To: Tom Rushing (DRC), Loren Morton (DRC), Phil Goble (DRC)
From: Paul Bitter (URS), Jeremy Cox (URS)
cc: Robert Baird (URS)
Date: 7 July 2011
Re: Comments on the Nitrate Investigafion Phase 2 Detailed Work Plan and Schedule for
White Mesa Mill Site dated July 1, 2011
This memorandum contams the URS and DRC comments on the Phase 2 Detailed Work Plan and
Schedule for the White Mesa Mill Site (Phase 2 Work Plan) dated July 1, 2011, which was
prepared by Denison Mines USA (DUSA). This review has been performed as a deliverable for
Contract No. 116259 issued through the Utah Department of Environmental Quality, Division of
Radiation Control (DRC). This review also is in accordance with the amended Memorandum of
Understanding (MOU) between the DRC and DUSA dated May 19, 2011. For purposes of
expediency, the URS and DRC comments are edited for conciseness and combined into one
memo. Note that format, grammar, and punctuation in the Work Plan were not reviewed for
accuracy and consistency.
The comments regarding the Phase 2 Work Plan are presented below. Please note that, per the
June 30, 2011 Revised Tolling Agreement (Rev. 2), all comments must be addressed and
resolved, and the revised Phase 2 Work Plan must be submitted, on or before July 13, 2011.
1. General Comment: The Phase 2 Work Plan is well-organized and adequately explains the
rationale for the proposed Phase 2 sampling locations and analyses.
2. General Comment: Please provide a reference section listing all sources cited in this
document.
3. Section 3.1: Cryptosporidium is not specific to cattle and livestock as stated in Section 3.1.
Please amend the language. DRC agrees that the presence of Cryptosporidium in the
groundwater will likely indicate an agricultural influence in the groundwater, however, this is
not definitive.
4. Section 3.1: DRC agrees that background determinations for RDX and KMX are
unnecessary.
5. Section 3.2: DRC agrees that nitrate and chloride need not be analyzed during the Phase 2
investigation because they are regularly monitored in the groundwater at the site.
6. Section 3.2: DRC agrees with the locations and number of samples for Cryptosporidium,
RDX, and KMX. DRC also agrees with the number and locations of additional wells to be
sampled for these analytes if further study is warranted based on data results from the initial
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set of wells. DRC also agrees with the number and locations of monitoring wells to be
sampled and analyzed for perchlorate.
7. Section 3.2, paragraph prior to Background Determination sub-section: This paragraph is not
consistent with the remainder of the text in the Phase 2 Work Plan. The paragraph currentiy
reads:
"As previously stated, if positive detections are reported in the initial screening, a background
determination for perchlorate would be completed. The background study would be
completed as described below."
Please replace the paragraph with the following sentence:
"The requirement for a site-specific perchlorate background study, and the methods for that
study, are described below."
8. Section 3.2, Background Determination: DRC agrees with the proposal to sample
background wells only if Cryptosporidium, RDX, or HMX are detected in any of the initial set
of monitoring wells planned for sampling by DUSA, or if perchlorate is detected above 1.0
\ig/L in any of the 12 monitoring wells selected by DUSA for the initial round of perchlorate
sampling. DRC agrees with the number and locations of the background monitoring wells.
9. Section 3.2, Background Determination: DRC requests that the phrase "basis for perchlorate
background determination" be revised to "basis for site-specific perchlorate background
determination". DRC agrees with the 1.0 ^g/L typical background screening level for
perchlorate provided by the literature cited by DUSA for nationwide groundwater sampling.
DRC agrees that exceedances of the 1.0 ^g/L value during the initial sampling event should
act as a trigger for sampling additional monitoring wells to determine a site-specific
background concentration for perchlorate in groundwater at the White Mesa mill site.
10. Attachment 1: Please include the schedule relative to the analysis of Cryptosporidium
samples.
11. Attachment 1: If the samples will be collected starting July 18 but not shipped until July 25,
how does DUSA propose to maintain the correct temperatures of the samples Hsted in
Attachment 2? This subject is not addressed in Attachment 2. Please revise the text
accordingly. In addition, the currently planned schedule would result in a violation of the
requested 7-day maximum holding time for groundwater samples being analyzed: for HMX
and RDX by Method 8330 (refer to comment #19 below) and is not acceptable. Please revise
the schedule to allow for shipment of all groundwater samples from wells being analyzed for
HMX and RDX so that the samples are shipped no later than the day of sample collection or
the day after sample collection. This will allow sufficient time for the analytical laboratory to
perform the extraction for Method 8330 within the maximum holding time.
12. Attachment 2: Please correct the spelling of "attachment" on the cover page.
13. Attachment 2: DRC appreciates the highlighting of the text derived directly from the QAP
for the ease of review.
14. Attachment 2, Section 2.4.2, second paragraph: No reason is provided for the lack of a
selection of a laboratory that will perform the Cryptosporidium analysis. If the monitoring
wells are scheduled to be sampled by July 18, the laboratory should have already been
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selected and placed under contract. Since the laboratory contracted for cr>^ptosporidium
analysis will not have NELAC or State Laboratory certification, this laboratoiy needs to be
identified as part of the Phase 2 Work Plan Attachment 2. Please ensure that every effort is
made to contract an environmental laboratory listed in the most recent revision of the
Environmental Protection Agency publication, "Laboratories Approved for the Analysis of
Cryptosporidium under the Safe Drinking Water Act." If the contracted laboratory is not
included on the EPA approved list, then please provide justification in Attachment 2 as to
why the Laboratory QA/QC procedures relative to the Cryptosporidium test methods are
sufficient to meet the goals of (he study objectives.
15. Attachment 2, Section 4.3.5: DRC requests that deionized water from a third-party
commercial source (not from the Mill) be used for the field blanks for the Phase 2
investigation.
16. Attachment 2, Section 6.2.10, second paragraph: Please delete the second sentence
regarding nitrate/ammonia analysis. This sentence does not appem* to be relevant to the Phase
2 investigation.
17. Attachment 2, Section 7.3: Refer to comment on Attachment 2, Section 2.4.2, second
paragraph.
18. Attachment 2, Sections 9.1 through 9.4: If the analytical laboratory reports detections of
HMX, RDX, cr>'ptosporidiuni, or perchlorate during Campaign 1 or Campaign 2, DRC will
require third-part}' validation of the analytical data. The presence of Cryptosporidium, RDX,
or HMX, or the presence of perchlorate above the background screening level, may indicate a
contributor other than mill activities and may significantiy affect the conclusions of the
nitrate investigation. Therefore, verifying the validity of the analytical results for the Phase 2
sampling is necessary. A third-party data validator is a company, unaffiliated with DUSA,
DRC, or their contractors, that employs personnel who specialize in reviewing data fi"om
analytical laboratories for the purposes of verifying the validity of the results. A data
validator reviews all of the available data, including results from field duplicates, field
blanks, and all laboratory quality control samples to assess the validity of the reported results.
The data validation is performed according to pre-determined guidelines. Because the data
validator reviews a broader range of quality control data than the analytical laboratory, trace
detections reported by an analytical laboratory can, in some cases, be flagged as uncertain or
changed to a non-detect value by the data validator.. The guidelines for the data validation
would be determined after a decision is made whether data validation is necessary.
The Co-Executive Secretary reserves the right to collect split samples from any of die
monitoring wells that DUSA samples during Campaign 1, Campaign 2, or background
sampling. DUSA must provide notice to DRC seven calendar days prior to each sampling
event to allow DRC personnel to be present for the collection of split samples.
19. Attachment 2, Revised Table 1: DRC requests that perchlorate be analyzed by a Utah-
certified environmental laboratory using USEPA Method 6850 or 6860, depending on the
laboratory's preference. Refer to the USEPA Test Methods for Evaluating Solid Waste for
details regarding these analyses. Use of EPA Method 331 is not acceptable, in that it is
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designed for drinking water and may be adversely affected by interferences (false positives)
caused by anions in the groundwater from this site. Furthermore, the reporting limit provided
for Method 331 is too high to meet the objectives of the Phase 2 investigation. DRG also
requests a 7-day maximum holding time until extraction for Method 8330; that holding time
is more appropriate for aqueous samples.
20. Attachment 2, Table 2: For Campaign 1, TWN-2 is listed twice. Please delete the additional
entry. For both Campaign 1 and 2, TWN-1 and TWN-24 are listed in the table, but Section
3.2 lists TW4-1 and TW4-24. Likewise, Figure 2 displays TW4-I and TW4-24 as Phase 2
sampling locations. Please update the entries for "TWN-l" and "TWN-24" in Table 1 to
"TW4-1" and "TW4-24". Attachment 2, Section 4.3.5 states that the DIFB sample will be
labeled with a sample ID such as MW-60. Please update the sample ID accordingly for the
DIFB samples in Table 2. Attachment 2, Section 8.1.2 states that the analytical laboratory
will perform matrix spikes and matrix spike duplicates. If the laboratory will require
additional sample volume to perform those tests, please indicate in Table 2 the wells from
which the additional sample volumes will be collected.
[End of comments]
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